Essays about: "Arm’s length"

Showing result 1 - 5 of 41 essays containing the words Arm’s length.

  1. 1. The Brazilian Adoption of the Arm's Length Principle : Considerations and its Impact on the Country's Fiscal Sovereignty in Cross-border Commodities Transactions

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Alexandre Magno Ramos Paiva; [2023]
    Keywords : Arm’s Length Principle; Practicability Principle; Transfer Pricing; Fiscal Sovereignty; Commodities.;

    Abstract : The thesis critically examines the Brazilian adoption of arm's length principle and assesses its impact on the country's fiscal sovereignty in cross-border commodities transactions. The arm's length principle is regarded as an useful tool for preventing tax avoidance and ensuring tax neutrality. READ MORE

  2. 2. The digital economy and its implications: does the OECD’s Pillar One Proposal challenge the principles of law within International and EU tax law?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Wihan Esterhuizen; [2023]
    Keywords : Tax; EU Law; OECD S Pillar One; principles of law; ability-to-pay; territoriality; state aid; transfer pricing; Arm s length principle; Law and Political Science;

    Abstract : Change is the only constant; yet, as we step into the brave new world of taxing the digital economy, it might seem like the need and development of principles and rules for adequate profit allocation has only begun. This thesis discusses the profit allocation rules under the Unified Approach of the OECD Pillar One Proposal Amount A in relation to three identified principles of law in international and European tax law. READ MORE

  3. 3. VISUAL ONION GROWTH STAGEDETERMINATION USING CNNS

    University essay from Mälardalens universitet/Akademin för innovation, design och teknik

    Author : Tony Mugisha; Pontus Gustavsson; [2023]
    Keywords : ;

    Abstract : With the growing agricultural sector, the demand for more harvest is increasing. Thus next stepin development is automating the agriculture sector. Onions are widely used in various dishes andhold a significant position as a crop of focus for Ekobot. READ MORE

  4. 4. Is control over risk getting out of control? : An analysis of the concept of control over risk as set out in the 2022 OECD Guidelines in relation to Swedish law

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Karolina Linusson; [2023]
    Keywords : control over risk; OECD Transfer Pricing Guidelines; transfer pricing; the arm s length principle; kontroll över risk; internprissättning; armlängdsprincipen;

    Abstract : In 2017 an amended version of the OECD Transfer Pricing Guidelines was published which included new provisions to prevent BEPS through the shifting of risks. Through the amendment of the Guidelines, it was clarified that for an entity in an MNE to contractually assume a risk, for transfer pricing purposes, it needs to control the risk and have the financial capacity to assume it. READ MORE

  5. 5. The Importance of Bacterial Replichore Balance

    University essay from Uppsala universitet/Institutionen för medicinsk biokemi och mikrobiologi

    Author : Ender Efe Cerit; [2021]
    Keywords : Salmonella; bacterial evolution; fitness cost; chromosome organization and structure; chromosomal inversion; replichore; horizontal gene transfer;

    Abstract : In most bacterial pathogens, the genome is comprised within a single circular chromosome which is typically organized by the origin-to-terminus axis that divides the chromosome into equally-sized arms of replication (replichores). This similarity in length is presumed to be required for the synchronization of the two replication forks to meet at the terminus for efficient chromosome segregation. READ MORE